Bank of America Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	Bank of America offers only limited insight into its climate-policy lobbying. The disclosures speak in broad terms about policy areas—such as support for “a price on carbon,” grid modernisation and electric-vehicle charging infrastructure—and note that the bank submitted a comment letter on the US SEC’s proposed climate-disclosure rule, but they do not catalogue any further specific bills or regulations it has tried to influence. References to activity, such as “public policy advocacy,” “direct engagement with regulators and policymakers,” participation in trade associations and coalitions, or the instruction to “Please refer to ‘Regulators and Policymakers’ in the Strategy section of 2024 Sustainability at Bank of America,” reveal that the bank uses both direct contact and industry groups, yet they stop short of naming the government departments, legislators or regulators approached, or describing concrete tools like meetings, letters or consultations. Likewise, the company articulates only high-level objectives—accelerating the net-zero transition, lowering the cost of clean technologies, and enabling a “just transition”—without specifying the legislative amendments, funding levels or timelines it is asking policymakers to adopt. Taken together, the disclosures demonstrate a willingness to discuss climate engagement in principle but provide scant detail on the precise policies, lobbying channels or outcomes pursued.	1

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Bank of America’s disclosures suggest that its lobbying activities are under formal oversight, noting that its “political activities and public policy engagement are subject to comprehensive governance, including oversight from our Board’s Corporate Governance, ESG, and Sustainability Committee.” It further describes that its “public policy team is engaged with policy makers across the globe to help ensure we understand and, where appropriate, work to influence potential policy changes that could impact the Company or our clients,” and that it is “collaborating with trade associations, through cross-sectoral and financial sector alliances, and with non-profit partners” to accelerate the low-carbon transition. However, the company does not disclose any specific policy, review process or criteria for aligning these direct and indirect lobbying activities with its climate commitments, nor any mechanism for monitoring or managing this engagement against its net-zero objectives.	1